Compliance Is Not a Checkbox: Lessons from the Todd Snyder Case
Privacy Enforcement

Compliance Is Not a Checkbox: Lessons from the Todd Snyder Case

Compliance with data privacy regulations isn’t just a one-time project—it’s an ongoing commitment. A recent enforcement action by the California Privacy Protection Agency (CPPA) against fashion designer Todd Snyder illustrates what can go wrong when that commitment wavers. The $345,000 settlement with Snyder’s company serves as a wake-up call for organizations treating compliance as a static checkbox rather than a dynamic process. 

This case is not just a cautionary tale; it’s a compelling reminder of why continuous compliance is essential, and also the driving force behind our recent release of our Compliance Advisor, which routinely scans your website for compliance gaps. In this blog, we’ll unpack what happened in the Todd Snyder case, examine the importance of ongoing compliance practices, and explore how solutions like Truyo’s Compliance Advisor help businesses stay ahead of privacy regulations every step of the way. 

The Todd Snyder Case: A Pricey Privacy Wake-Up Call 

In April 2025, the CPPA announced a $345,000 settlement with Todd Snyder LLC for multiple violations of the California Consumer Privacy Act (CCPA), marking one of the agency’s most high-profile enforcement actions to date. This fine followed a CPPA review that found glaring compliance failures across several core areas of the law. 

Key violations included: 

  • Missing Opt-Out Mechanism: The company failed to include a “Do Not Sell or Share My Personal Information” link on its website, a clear requirement under the CCPA for businesses that engage in the sale or sharing of consumer data.
  • Inadequate Notice at Collection: Consumers were not properly informed about the categories of personal information being collected or the purposes for that collection—another basic CCPA requirement. 
  • Incomplete Privacy Policy: The company’s privacy policy lacked required disclosures about consumer rights and how those rights could be exercised. 
  • Insufficient Response to Consumer Requests: There were also issues with how Todd Snyder LLC responded to data subject requests, indicating a lack of operational readiness. 

This case is particularly significant because it reflects the CPPA’s growing willingness to use its enforcement authority and signals that even fashion retailers—not just tech giants—are within its regulatory crosshairs. It also underscores the variability of compliance and its need for more than a one-time implementation that goes unchecked. While Todd Snyder claimed it was only out of compliance for a few weeks, that was long enough to catch the eye of the CPPA. If an employee within your organization made an unapproved or unintended change to the cookie collection, would you know, and how quickly? 

What Could Have Helped Todd Snyder? Meet Truyo’s Compliance Advisor for Proactive Privacy Monitoring & Real-Time Privacy Audits 

Ensuring compliance isn’t just about internal processes—it’s about what the public sees when they visit your website. This is where Truyo’s Compliance Advisor plays a vital role in your ongoing privacy program. It acts as a vigilant, automated system that routinely inspects your website to confirm that essential privacy components are in place and visible, aligning your public presence with legal obligations. 

This level of vigilance is exactly what could have helped Todd Snyder LLC avoid its recent $345,000 fine from the California Privacy Protection Agency (CPPA). One of the major failings in that case was the absence of a publicly visible “Do Not Sell or Share” link, alongside issues with the site’s privacy policy and cookie consent mechanisms. These are precisely the areas the Compliance Advisor is designed to monitor and report on. By automatically flagging such gaps before they escalate into enforcement actions, Truyo provides organizations with a critical safety net. 

Had a system like Compliance Advisor been in place, Todd Snyder’s team could have received early alerts about missing opt-out links and other required disclosures—giving them time to address the issues before facing regulatory scrutiny. In this way, Truyo doesn’t just support compliance—it actively helps organizations avoid the reputational and financial fallout of non-compliance. 

What Is the Compliance Advisor? 

The Compliance Advisor is a web domain scanning utility built directly into the Truyo platform. It’s designed to automatically evaluate your website’s public-facing privacy signals and infrastructure, helping organizations detect gaps before regulators or users do. Think of it as your digital privacy watchdog—constantly checking for key compliance indicators and flagging any misalignments with privacy laws like the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). 

Key Compliance Checks 

For every domain you register in the platform, the Compliance Advisor conducts a deep scan and returns detailed insights on the presence or absence of: 

  • “Do Not Sell or Share” Link 
    • Confirms whether your website offers a visible opt-out mechanism as required by CCPA/CPRA. 
    • Scans headers, footers, or dedicated sections for the correct link format. 
  • Privacy Policy Availability 
    • Detects whether a privacy policy link exists. 
    • Verifies that the link works, is clearly labeled, and points to an accessible page. 
  • Cookie Banner Presence 
    • Identifies if your site uses a cookie consent banner. 
    • Includes vendor detection to determine who created the banner. 
  • Global Privacy Control (GPC) Support 
    • Checks whether your site honors the GPC HTTP header, a browser-based signal that communicates a user’s global opt-out preference. 
  • Tag Manager Detection 
    • Scans for the use of tag management tools like: 
      • Google Tag Manager (GTM) 
      • Tealium 
      • Adobe Launch 
    • Helps understand how data tracking is implemented across the site. 

How It Works 

Admins simply enter their web domains into the Truyo platform. Using advanced techniques—such as a headless browser or a crawler simulation—the Compliance Advisor “visits” your website just like a real user would. It analyzes: 

  • Page content 
  • JavaScript 
  • Header elements 
  • HTTP responses 

All scan results are displayed in a user-friendly summary dashboard, providing a real-time snapshot of your domain’s privacy compliance health. 

Strategic Role Within the Truyo Platform 

The Compliance Advisor is more than just a utility—it’s a strategic component of your full compliance lifecycle. Here’s how it fits: 

  • External Validation: It serves as a verification layer to ensure your internal privacy settings and declarations (e.g., consent mechanisms, data subject access request workflows) are properly reflected on your public website. 
  • Remediation Workflow Trigger: If gaps are found—such as a missing “Do Not Sell” link—it can initiate internal review and correction processes. 
  • Complements Consent & Assessment Tools: It rounds out Truyo’s privacy ecosystem, offering visibility into areas often missed in traditional audits. 

Compliance Isn’t One and Done 

The Todd Snyder case demonstrates that compliance isn’t something you do once and forget. Laws like the CCPA and CPRA evolve, and so must your compliance efforts. A policy created three years ago won’t be sufficient if your website, data collection methods, or legal obligations have changed in the meantime. 

Why ongoing compliance matters: 

  • Laws Change: New amendments to the CCPA, the rollout of CPRA, and additional privacy laws in other states mean that your obligations can shift from year to year—or even quarter to quarter. 
  • Technology Evolves: If you change your data management platforms, add analytics tools, or adopt new customer engagement technologies, your compliance posture may be impacted. 
  • Consumer Expectations Grow: Beyond legal obligations, consumers now expect transparency and control over their data. Failing to meet those expectations can harm your reputation and erode trust. 
  • Enforcement Is Active: With the CPPA actively investigating companies, the risk of being caught non-compliant is higher than ever. And as seen in the Todd Snyder case, the penalties are significant—not just financially but reputationally. 

The Compliance Lifecycle: A Continuous Process 

Treating compliance as a lifecycle rather than a one-time event is essential for long-term success. A robust privacy program should incorporate the following elements: 

  1. Initial Assessment and Gap Analysis
    • Understand what data you collect, process, and store. 
    • Identify gaps between current practices and legal requirements. 
  1. Policy Development and Communication
    • Draft clear privacy policies and notices. 
    • Ensure these documents are accessible and understandable to consumers. 
  1. Implementation of Consumer Rights Mechanisms
    • Enable data access, deletion, and opt-out requests. 
    • Build workflows to process and respond to these requests on time. 
  1. Routine Monitoring and Auditing
    • Periodically review your website and data practices. 
    • Use automated tools to catch lapses early. 
  1. Staff Training and Awareness
    • Keep your team up-to-date on the latest laws and internal procedures. 
    • Foster a culture of privacy and accountability. 
  1. Updates and Continuous Improvement
    • Stay informed on regulatory changes. 
    • Revise policies and procedures as needed. 

Failing at any one stage of this cycle can lead to the kind of compliance gaps that resulted in the CPPA’s action against Todd Snyder LLC. 

How Truyo Keeps You Ahead of Compliance Risks 

Navigating data privacy laws doesn’t have to be overwhelming, especially when you have the right tools and partners. Truyo offers a proactive, ongoing approach to compliance that goes well beyond the initial implementation. 

Here’s how Truyo supports your compliance journey: 

  • Compliance Advisor: This feature routinely scans your website for potential gaps—like missing opt-out links or outdated privacy notices—helping you fix issues before regulators notice them. 
  • Automated Workflows: Truyo streamlines the intake and processing of data subject requests, ensuring timely and accurate responses that meet legal requirements. 
  • Policy and Notice Management: With built-in tools to update and manage privacy notices, Truyo makes it easier to stay current as laws evolve. 
  • Regulatory Monitoring: Truyo stays on top of changing laws across jurisdictions, alerting you to relevant updates that may affect your operations. 
  • Audit Trails and Reporting: Truyo offers the documentation you need to demonstrate compliance in the event of an audit or inquiry—something that Todd Snyder LLC evidently lacked. 

Make Compliance Your Competitive Advantage 

The Todd Snyder enforcement action should not be viewed in isolation—it’s a signal to all businesses that regulators are watching and that the bar for compliance is rising. Treating compliance as a living, breathing process rather than a one-time fix isn’t just smart—it’s essential. 

With Truyo as your partner, you’re not only checking the box today—you’re setting up a system to manage compliance tomorrow and beyond. From real-time website checks to end-to-end consumer rights management, Truyo equips your business to meet privacy obligations continuously and confidently. 

To learn more about how Truyo’s Compliance Advisor can help you stay on top of evolving privacy requirements, visit truyo.com or email hello@truyo.com to request a demo of our Compliance Advisor or the full platform.  


Author

Dan Clarke
Dan Clarke
President, Truyo
May 15, 2025

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